Food safety is often about battling the enemy you can’t see — ­allergens and pathogens — in the most likely of places such as food-contact surfaces in prep areas and on equipment. Efficient bakery production is all about timing, so any downtime comes with dollar signs, especially as the finalization of the Food Safety Modernization Act (FSMA) looms on the horizon.

In this exclusive report, Baking & Snack editor Dan Malovany and managing editor Joanie Spencer sat down with contributing editor Joe Stout, CEO and founder of Commercial Food Sanitation LLC, to find some preventive best practices for keeping equipment and all surfaces food-safe and audit-ready while avoiding costly stoppages.

Mr. Stout knows more than almost anybody in the world about sanitation and food safety, after working 29 years for Kraft Foods, eventually as director of global product protection, sanitation and hygienic design. While at Kraft, he oversaw global responsibility for manufacturing plant cleaning controls and processes, allergen and pathogen control programs, pest control and hygienic design for facilities and equipment used in more than 200 Kraft plants to ensure the equipment and facilities were cleanable and effectively sanitized.

Baking & Snack: According to proposed FSMA regulations, what is the definition of a “contact surface”?

Joe Stout: In the proposed FSMA preventive control rule, food-contact surfaces are defined as “those surfaces that contact human food and those surfaces from which drainage, or other transfer, onto the food or onto surfaces that contact the food ordinarily occurs during the normal course of operations.” The phrase “food-contact surfaces” includes utensils and food-­contact surfaces of equipment.

Baking & Snack: What kinds of materials are permitted? What is the ideal material for a contact surface in terms of food safety vs. usability?

Based on the proposed rule of preventive control (117.40), ­requirement of materials used for equipment and utensils is stated as below:

 (a) (1) All plant equipment and utensils must be so designed and of such material and workmanship as to be adequately cleanable, and must be properly maintained. (2) The design, construction and use of equipment and utensils must preclude the adulteration of food with lubricants, fuel, metal fragments, contaminated water, or any other contaminants. (3) All equipment should be so installed and maintained as to facilitate the cleaning of the equipment and of all adjacent spaces. (4) Food-contact surfaces must be corrosion-resistant when in contact with food. (5) Food-contact surfaces must be made of nontoxic materials and designed to withstand the environment of their intended use and the action of food, and, if applicable, cleaning compounds and sanitizing agents. (6) Food-contact surfaces must be maintained to protect food from cross-contact and from being contaminated by any source, including unlawful indirect food additives.

(b) Seams on food-contact surfaces must be smoothly bonded or maintained so as to minimize accumulation of food particles, dirt and organic matter and thus minimize the opportunity for growth of microorganisms and cross-contact.

(c) Equipment that is in the manufacturing or food-handling area and that does not come into contact with food must be so constructed that it can be kept in a clean condition.

(d) Holding, conveying, and manufacturing systems, including gravimetric, pneumatic, closed and automated systems, must be of a design and construction that enables them to be maintained in an appropriate sanitary condition.

What types of materials should bakers avoid, according to rules for sanitary design for baked goods?

Materials that are not easy to clean and materials such as wood or fabric (fiber or fabric-backed belting), which are absorbent to moisture, need to be avoided. These materials may result in foreign objects in food, cross-contamination of allergens in food and microbial activity. More stainless steel, or single-­filament belting with smooth, cleanable ­surfaces are recommended.

Describe some best practices for work areas from prep to breakdown.

Provide areas where employees can change into clean clothing and wash hands to ensure they are hygienically prepared to work in a food plant and come in contact with food.

It all starts with sanitation and having a clean plant prior to producing food for consumers to eat. The plant must be clean.

Have appropriate separation of raw areas from those ready-to-eat areas and separation or controls of allergens from non- or different allergens to avoid cross contamination.

What are some of the lesser-known regulations regarding contact surfaces that bakers should be aware of? Is there a rule that bakers might not realize they’re breaking?

People normally think bakery is different from other food categories such as meat or dairy. However, the “kill” step in bakery (heat, ovens if validated) does not prevent cross contamination from pathogens like Salmonella or Listeria moncytogenes, following the kill step. Bakery has some of the same microbiological risks as other products and, therefore, requires a kill step and separation of areas (raw from RTE) as well as other tools and programs to help avoid the potential for cross contamination.

In terms of third-party audits, what can bakers do to make sure their contact surfaces are audit ready?

The newly proposed rules on third-party auditing and foreign supplier verification program will ensure that auditing plays a more important role in ensuring food safety. These rules will have to integrate the preventive control rule in which hygienic and sanitary equipment surfaces are critical in the preventive food safety plans.

Currently, third-party auditors spend time evaluating system documentation; however, as part of this review, they may look at specifications for contact surfaces and then observe contact surfaces during their plant review. To better prepare for the new regulations and third-party auditing, I would suggest completing design reviews of equipment, using the Grocery Manufacturers Association (GMA) sanitary design checklists to understand what you have and the associated risks. These can be found at under “Documents.”

Following the cleaning of a production line, what are the best procedures for ensuring food safety? Where should bakers look to check for allergens or swab for pathogens?

After a production line is cleaned, attention needs to be focused on cleanliness to avoid cross contamination from a previous run or the environment. Therefore, prior to production, the cleanliness of equipment should be verified to ensure the established criteria for making safe product is met or exceeded. Depending on the line, plant and product, this could mean testing for allergens or microorganisms. Commercially available kits can be used to perform the tests. The surfaces can be sampled using tools such as swabs for areas of concern.

What’s the best advice you have for ensuring that contact surfaces are clean and safe for production?

From a strategic perspective, I would encourage plant personnel get familiar with and understand the principles of equipment design and fully take advantage of those learnings as they design equipment. To make safe food, we must start with cleanable equipment, which is not guaranteed unless we have good designs. When the industry understands and uses the principles, it will become possible for continuous improvement in sanitary design.

From a tactical perspective, if we could make equipment more accessible for cleaning, that would solve half of our challenges. When one completes a GMA checklist for the 10 principles of sanitary design for equipment, many of the issues are related to the lack of easy access to clean the equipment. As the suppliers make more equipment that is easily accessed for cleaning, and processors purchase and install it, that would be a significant improvement to ensure food contact surfaces are cleaner and safer for food production.